Comment Letters

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Comment Letter

ICI Supplemental Comment Letter on the SEC’s 2020 Disclosure Proposal Related to Performance Benchma...

Earlier this week, ICI submitted supplemental comments (linked below) on the SEC's 2020 disclosure...

Comment Letter

ICI Comment Letter to CFTC and SEC on CCP Governance and Conflicts of Interest Proposals

ICI filed this comment letter with the CFTC on its DCO governance rule proposal and the SEC on its...

Comment Letter

Joint Comment Letter Responding to PRA/FCA Consultation

On October 3, ICI co-signed a letter with several associations (the Associations) in response to a...

Comment Letter

ICI Comment Letter to FINRA and MSRB Regarding Shortening Trade Reporting Timeframes

On October 3, 2022, ICI filed a comment letter on behalf of members discussing certain concerns with...

Comment Letter

ICI Comment Letter on the SEC's Rule 14a-8 Proposal

In July 2022, the SEC proposed amendments to Rule 14a-8 (the shareholder proposal rule) by a 3-2...

Comment Letter

ICI Comment Letter to Treasury Department on Additional Post-Trade Transparency

On August 19, ICI filed a comment letter discussing member views regarding the issues raised in the...

Comment Letter

ICI Comment Letter to OECD Requesting Clarifications to Asset Manager Exclusion from Pillar One Amou...

ICI submitted this response to the OECD ’s Progress Report on Amount A of Pillar One ( “Progress...

Comment Letter

ICI Supplemental Comment Letter on SEC's Proposed Money Market Fund Reforms

On August 8, ICI filed this letter with the Securities and Exchange Commission to supplement our...

Comment Letter

ICI Comment Letter on Certain Information Providers Acting as Investment Advisers

In June, the SEC issued a request for comment on index providers, model portfolio providers, and...

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